Privacy Policy

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

APRIL 14, 2003

SUMMARY OF YOUR PRIVACY RIGHTS

At Narconon Arrowhead we are committed to preserving the privacy and confidentiality of your health information whether created by us or maintained on our premises. We are required by certain federal and state regulations to implement policies and procedures to safeguard the privacy of your health information. Copies of our privacy policies and procedures are maintained in the legal office. We are required by state and federal regulations to abide by the privacy practices described in this notice including any future revisions that we may make to the notice as may become necessary or as authorized by law.

Individually identifiable information about your past, present, of future health or condition, the provisions of health care to you, or payment for the health care treatment or services you receive is considered protected health information. As such, we are required to provide you with this Privacy Notice that contains information regarding our privacy practices that explains how, when and why we may use or disclose your protected health information and your rights and our obligations regarding any such uses or disclosures. Except in specified circumstances, we will use or disclose only the minimum necessary protected health information to accomplish the intended purpose of use or disclosure of such information.

We have a limited right to use and disclose your health information for purposes of treatment, payment, or for the operations of our facility. For other purposes, you must give us your written authorization to release your protected health information unless the law permits or requires us to make the use or disclosure without your authorization.

We may use a limited amount of your protected health information when raising money for our facility and its operations. We may also disclose this information to a foundation related to the facility so that the foundation may contact you to raise money on behalf of our facility. The information we may use will be limited to your name, address, telephone number, and dates for which you received services at our facility. If you do not wish to be contacted for participation in fundraising activities or have this information provided to our affiliated foundation, you must provide us with a written notification. The name of the person to contact and the method of contacting him are listed on the last page of this notice. You must use our Request to Restrict the Use and Disclosure of Protected Health Information form to submit your request to us. Copies of this form are available in the legal office.

I. Understanding Your Health Record & Information.

When you enroll at Narconon Arrowhead a record of personal health information is created. As you progress through your services at our center, this record is updated. Typically, this record contains your symptoms, examination, lab test results, diagnoses, and plan for future care. This information, often referred to as your health record, serves as a:

* Plan for your care and treatment
* Communication source between health care professionals
* Tool with which we can check results and continually work to improve the care we provide
* Means by which private insurance payers can verify the services billed
* Legal document that describes the care you receive.

Understanding what is in your health record and how the information is used helps you to:

Although your health record is the physical property of Narconon Arrowhead, the information belongs to you. You have the right to:

* Inspect and receive a copy of your health record. You have the right to inspect and copy your health information, such as your medical and billing records that we use to make a decision about your care and services. In order to inspect or copy your health information, you must submit a written request to us. If you request a copy of your medical information, we may charge you a reasonable fee for the paper, labor, mailing, and retrieval costs involved in filling your request. You may submit your request on the Request for Inspection/Copy of Protected Health Information form, which is available in the legal office. We will respond within thirty (30) days of receipt of such requests. Should we deny your request to inspect and/or copy your health information, we will provide you with written notice of our reasons of the denial and your rights for requesting a review of our denial.

* Request a restriction on certain uses and disclosures of your health information. You have the right to request that we limit how we use or disclose your protected health information for treatment, payment or health care operations. You also have the right to request a limit on the health information we disclose about you to someone who is involved in your care or the payment for your care or services. For example, you may ask that Narconon not disclose your health information or course of treatment to a family member.

* Request a correction/amendment to your health record if you believe the health information we have about you is incorrect or incomplete. You have the right to make such a request of us as long as we maintain/retain your health record. We will respond within sixty (60) days of receipt of your written request. We may deny your request if: a) your request is not submitted in writing; b) your written request does not contain a reason to support your request; c) the information was not requested by us, unless the person or entity that created the information is no longer available to make the amendment; d) it is not part of the health information kept by our facility; e) it is not part of the information which would be permitted to inspect and copy; or f) the information is already accurate and complete. If your request is denied, we will provide you with a written notification of the reason(s) for such denial and your rights to have the request, the denial, and any written response you may have relative to the information and denial process appended to your health record.

* Request confidential communication about your health information. You may ask that we communicate with you at a location other than your home or by a different means of communication such as telephone or mail. To request confidential communications you must: a) notify us in writing; b) indicate the information you wish to limit; c) indicate whether or not you wish to limit or restrict our use or disclosure of such information; and d) identify to whom the restrictions apply (that is, which family member(s), agency, etc.)

* Receive a listing of certain disclosures Narconon Arrowhead has made of your health information upon request. This information is maintained for six (6) years or the life of the record, whichever is longer. You have the right to request that we provide you with a listing of when, to whom, for what purpose, and what content of your protected health information we have released over the specified period of time. This accounting will not include any information we have made for the purposes of treatment, payment, or health care operations or information released to you, your family, or disclosures made for national security purposes, or any releases pursuant to your authorization. Your request may not include releases prior to April 14, 2003. We will respond to your request within sixty (60) days of the receipt of your written request. Should additional time be needed to reply, you will be notified of such extension. However, in no case will such extension exceed thirty (30) days.

* Revoke your written authorization to use or disclose health information. This does not apply to health information already disclosed or used in circumstances where we have taken action on your authorization or the authorization was obtained as a condition of obtaining insurance coverage and the insurer has a legal right to contest a claim under the policy or the policy itself.

* Obtain a copy of the Narconon Arrowhead Notice of Privacy Practices upon request.

III. Narconon Arrowhead’s Responsibilities

Narconon Arrowhead is required by law to:

* Maintain the privacy of your health information
* Inform you about our privacy practices regarding health information we collect and maintain about you.
* Notify you if we are unable to agree to a requested restriction.
* Accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations.
* Honor the terms of this notice or any subsequent revisions of this notice.

Narconon Arrowhead reserves the right to change its privacy practices and to make the new provisions effective for all protected health information it maintains. If Narconon Arrowhead makes any significant changes to this Notice, it will send you a copy within 60 days. Narconon Arrowhead will post any revised Notice of Privacy Practices in a public place in its facility and on its web site at http://www.stopaddiction.com/ and you may also request a copy of the Notice.

Narconon Arrowhead understands that health information about you is personal and is committed to protecting your health information. Narconon Arrowhead will not use or disclose your health information without your permission, except as described in this Notice and as permitted by the Privacy Act.

IV. How Narconon Arrowhead will use and disclose health information about you.

The following categories describe how we may use and disclose health information about you:

We will use and disclose your health information to provide your treatment by medical professionals.

For example: Your personal health information will be recorded in your health record and used to determine the course of medical treatment for you. Your health care providers will record the actions they take in your health record so that other health care providers will know how you are responding to medical treatment.

If Narconon Arrowhead refers you to another health care facility or provider, Narconon Arrowhead may disclose your relevant health information to that health care provider for treatment purposes only.

We will use and disclose your health information for payment purposes.

For example: If you have private insurance a bill will be sent to your health plan for payment. The information accompanying the bill will include information that identifies you as well as your diagnosis, procedures, and supplies used for your treatment.

We will use and disclose your health information for health care operations.

For example: We may use your health information to evaluate your care and outcomes with our quality improvement team. This information will be used to continually improve the quality and effectiveness of the services we provide.

Business Associates: Narconon Arrowhead may provide some healthcare services and related functions the use of contracts with business associates. In such an instance Narconon Arrowhead may disclose your health information to business associates so that they can perform their jobs. We require our business associates to protect and safeguard your health information in accordance with all applicable federal laws.

Interpreters: In order to provide you proper care services, Narconon Arrowhead may use the services of an interpreter. This may require the use or disclosure of your personal health information to the interpreter. We require any interpreter to protect and safeguard your health information in accordance with all applicable federal laws.

Uses and Disclosures about Decedents: Narconon Arrowhead may use or disclose health information about decedents to a coroner or medical examiner for the purpose of identifying a deceased person, determining the cause of death, or other duties are authorized by law. Narconon Arrowhead may disclose health information to funeral directors consistent with applicable laws as necessary to carry out their duties.

Workers Compensation: Narconon Arrowhead may use or disclose your health information for workers compensation purposes as authorized or required by law.

Public Health: Narconon Arrowhead may use or disclose your health information to public health or other appropriate government authorities as follows: (1) Narconon Arrowhead may use or disclose your health information to government authorities that are authorized by law to collect or receive such information for the purpose of preventing or controlling disease, injury, or disability, or conducting public health surveillance, investigations, and interventions; (2) Narconon Arrowhead may disclose your health information to government authorities that are authorized by law to receive reports of child abuse or neglect; (3) Narconon Arrowhead may disclose your health information to government authorities that are authorized by law to receive reports of other abuse, neglect, or domestic violence as required by law, or as authorized by law if Narconon Arrowhead believes it is necessary to prevent serious harm; and (4) when authorized by law, Narconon Arrowhead may disclose your health information to an individual who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition.

Health Oversight Authorities: Narconon Arrowhead may use or disclose your health information to health oversight agencies (for example, Oklahoma Department of Mental Health & Substance Abuse Services) for activities authorized by law. These oversight activities include: investigations, audits, inspections and other actions. Narconon Arrowhead is required by law to disclose protected health information to the Secretary of Health and Human Services to investigate or determine compliance with the HIPAA privacy standards.

Compelling Circumstances: Narconon Arrowhead may use or disclose your health information in certain other situations involving compelling circumstances affecting the health or safety of an individual. For example, in certain circumstances: (1) we may disclose limited protected health information where requested by a law enforcement official for the purpose of identifying or locating a suspect, fugitive, material witness or missing person; (2) we may use or disclose protected health information if we believe it is necessary to prevent or lessen a serious or imminent threat to the health and safety of a person; (3) we may use or disclose protected health information to report a crime committed on Narconon Arrowhead premises; and (4) we may make any other disclosures that are required by law.

Non Violation of this Notice: Narconon Arrowhead is not in violation of this Notice or the HIPAA Privacy Rule if any of its employees or its contractors (business associates) discloses protected health information under the following circumstances:

•1. Disclosure by Whistleblowers: If a Narconon Arrowhead employee or contractor (business associate) in good faith believes that Narconon Arrowhead has engaged in conduct that is unlawful or otherwise violates clinical and professional standards or that the care or services provided by Narconon Arrowhead had the potential of endangering one or more students or members of the workplace or the public and discloses such information to:

•a. A public health oversight authority (for example, the Oklahoma Department of Mental Health & Substance Abuse Services) authorized by law to investigate or otherwise oversee the relevant conduct or the suspected violation, or an appropriate health care accreditation organization for the purpose of reporting the allegation of failure to meet professional standards or misconduct by Narconon Arrowhead; or

•b. An attorney on behalf of an employee or contractor (business associate) for the purpose of determining their legal options regarding the suspected violation.

•2. Disclosures by Employee Crime Victims: Under certain circumstances, a Narconon Arrowhead employee (or contractor) who is a victim of a crime on

or off the premises may disclose information about the suspect to law enforcement officials provided that:

•a. The information disclosed is about the suspect who committed the criminal act.

•b. The information disclosed is limited to identifying and locating the suspect.

•3. Reports of Suspected Child Abuse and Neglect: The restrictions on disclosure and use in the federal law and regulations do not apply to reporting under state laws of incidents of suspected child abuse and neglect, to the appropriate state and local authorities.

Any other uses and disclosures will be made only with your written authorization, which you may later revoke in writing at any time. (Such revocation would not apply where the health information already has been disclosed or used or in circumstances where Narconon Arrowhead has taken action in reliance on your authorization or the authorization was obtained as a condition of obtaining insurance coverage and the insurer has a legal right to contest a claim under the policy or the policy itself.)

To exercise your rights under this Notice, to ask for more information, or to report a problem contact:

Mike St. Amand

HIPAA Compliance Officer

HC 67 Box 5

Canadian, OK 74425

918-339-5800 ext. 702

If you believe your privacy rights have been violated, you may file a written complaint with: